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S.D.N.Y.Procedural orderFiled Feb. 25, 2022

Medidata Solutions, Inc. v. Veeva Systems Inc.

Judge
Jed Rakoff
Docket
1:17-cv-00589
Court
U.S. District Court · Southern District of New York
Pages
2
EvidenceCivil Procedure
In one sentence

In Medidata Solutions v. Veeva Systems, Judge Schofield granted Medidata’s motion to exclude evidence and argument about related California litigation from trial.

Who this affects

Medidata and Veeva are affected because neither party may introduce evidence or argument about the California litigation at trial.

What happened

In Medidata Solutions, Inc. v. Veeva Systems Inc., Veeva had filed a separate California lawsuit concerning employee agreements and their noncompetition provisions. That litigation was ongoing.

Medidata asked the court to prevent the parties from presenting evidence or argument about the California case. The court found the lawsuit irrelevant to the remaining trade-secret claims and likely to confuse the jury.

Judge Lorna G. Schofield granted Medidata’s motion. The parties may not introduce evidence or argument about the California litigation at trial.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Medidata Solutions, Inc. v. Veeva Systems Inc. · No. 1:17-cv-00589
Judge
Jed Rakoff
Date
Feb. 25, 2022

Background

Medidata moved to exclude evidence and argument concerning a parallel California lawsuit involving the parties. Veeva opposed the motion.

In July 2017, Veeva sued Medidata and two other defendants in California state court. Veeva sought a declaration that Medidata’s agreements with several employees accused of trade-secret misappropriation were unlawful because they contained noncompetition provisions that violated California law. The California complaint also briefly referred to broad confidentiality obligations in those agreements. The California lawsuit was ongoing.

Court’s reasoning

Medidata had originally asserted claims for tortious interference, unfair competition, aiding and abetting breaches of fiduciary duties, and unjust enrichment. The court’s earlier summary-judgment decision held that those claims were preempted under California law, leaving only the trade-secret-misappropriation claims. The parties agreed that the California lawsuit was not relevant to those remaining claims. The court also found a substantial risk that introducing evidence about the California litigation would confuse the jury.

Ruling

Judge Lorna G. Schofield granted Medidata’s motion in limine, identified as Medidata MIL 11. The parties may not introduce evidence or argument regarding the California litigation at trial. The Clerk of Court was directed to close the motion at Docket No. 486.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

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